I just noted this addition to the Italian Royal Army Command Rules in the Equipment Pack Rules:

"When the Italian High Command rules are in effect its army starts the battle with 6 Command cards in hand. Each time a unit is lost, one Italian one Italian player's Command card is selected at random by his opponent and discarded. However the number of Command cards held by the Italian player cannot be reduced below three.

In the Mediterranean Theatre expansion rules the Italian Royal Army Rules only mention "Motorized Divisions" and "Artillery Bravery", not the above section.